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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time the petition was filed,
petitioner resided in Lake Placid, New York.
Petitioner incorporated FSRC in 1963. FSRC acquired land in
Howell Township, New Jersey (the Township), upon which it
operated a camping and recreational business, known as Deep
Hollow Park. Business activities at Deep Hollow Park included
selling swimming memberships, renting recreational vehicles,
mobile homes, and trailers, and providing space for overnight
camping. Petitioner owned 49 of the 50 initial outstanding
shares of stock in FSRC, and petitioner's wife owned the
remaining share.2 The total number of shares outstanding
eventually increased to 100.3
On June 16, 1980, the board of directors of FSRC approved a
conditional purchase contract to purchase property adjacent to
Deep Hollow Park. The contract was subject to the corporation's
receiving the necessary approvals from the Township for its
2In the mid-1970's, petitioner acquired his wife's share.
3Petitioner testified that by 1988, he had given 90 shares
of FSRC stock to his daughters. However, he produced no
documentation of the transfer, he never filed any gift tax
returns with respect to the transfer of these shares, and he
reported that he had received the entire 1988 liquidating
distribution on his own return.
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